NASF submitted comments to the Office of Procurement and Property Management on July 2, in response to the Notice of Proposed Rulemaking on Guidelines for Designating Biobased Products for Federal Procurement amendments. The comments stated that NASF has a strong interest in the inclusion of forest products, particularly wood, in the Biobased Markets Program. The comments went on to highlight the advantages of forest products, including the points that they are renewable, sustainable, and contain some of the highest concentrated biobased material. As a manufactured product from forests, wood contains 100% biobased material that is utilized in building structures, furniture and many other products. Considering that the intent of the Biobased Market Program is to increase the demand for such products (as well as help support rural development efforts), it is contradictory to exclude a product as environmentally beneficial and high biobased content as wood.
NASF does not support the bias towards products that promote “new and emerging markets” if it continues to prevent forest products access into the program. The preference towards emerging markets actually distorts the market based on market maturity rather than a more applicable criterion (e.g., environmental impact). Despite the inclusion of forestry materials in the definition of biobased products, current program rules disallow products with mature markets. The consequence of this restriction results in the harmful effect of excluding forestry products at a time when forest markets are in decline.